Staff Report

A P LEX ADILLA |SECRETARY OF STATE | STATE OF CALIFORNIA OFFICE OF VOTING SYSTEMS TECHNOLOGY ASSESSMENT 1500 11th Street | Sacramento, CA 95814 | Tel 916.695.1680 | Fax 916.653.4620 | www.sos.ca.gov KNOW NK, LLC’ P P I S OLL AD Version 2.5.2.01b Apple iPad, Generation 5, 32 Gigabyte Apple iPad, Generation 6, 32 Gigabyte Apple iPad, Generation 6, 32 Gigabyte (Cellular) Apple iPad, Generation 6, 128 Gigabyte Apple iPad, Generation 7, 32 Gigabyte Apple iPad, Generation 7, 32 Gigabyte (Cellular) Apple iPad Air 2, 16 Gigabyte iOS, Version 13.6 iOS, Version 13.6.1 iOS, Version 13.7 PollPad Application, Version 2.5.2.01b Star Micronics Printer, Model TSP650II Star Micronics Printer, Model TSP700II Brother Pocket Printer, Model JET PJ-763MFi ePulse, Version 2.5.2.01b Staff Report Prepared by: Secretary of State’s Office of Voting Systems Technology Assessment October 3, 2020 A P LEX ADILLA |SECRETARY OF STATE | STATE OF CALIFORNIA OFFICE OF VOTING SYSTEMS TECHNOLOGY ASSESSMENT 1500 11th Street | Sacramento, CA 95814 | Tel 916.695.1680 | Fax 916.653.4620 | www.sos.ca.gov Table of Contents I. Introduction .....................................................................................................2 1. Scope ...............................................................................................2 2. Summary of the Application ...........................................................2 3. Contracting and Outsourcing ..........................................................2 II. Summary of the System .................................................................................3 1. Apple iPad, Generation 5, 32 Gigabyte ..........................................3 2. Apple iPad, Generation 6, 32 Gigabyte ..........................................3 3. Apple iPad, Generation 6, 32 Gigabyte (Cellular) ..........................3 4. Apple iPad, Generation 6, 128 Gigabyte ........................................3 5. Apple iPad, Generation 7, 32 Gigabyte ..........................................3 6. Apple iPad, Generation 7, 32 Gigabyte (Cellular) ..........................3 7. Apple iPad Air 2, 16 Gigabyte ........................................................3 8. iOS, Version 13.6 ............................................................................3 9. iOS, Version 13.6.1 .........................................................................3 10. iOS, Version 13.7 ............................................................................3 11. PollPad Application, Version 2.5.2.01b..........................................3 12. Star Micronics Printer, Model TSP650II ........................................3 13. Star Micronics Printer, Model TSP700II ........................................4 14. Brother Pocket Printer, Model JET PJ-763MFi ..............................4 15. ePulse, Version 2.5.2.01b ...............................................................4 III. Testing Information and Results ....................................................................4 1. Background .....................................................................................4 2. Functional Testing Summary ..........................................................4 3. Software (Source Code) Review Testing Summary .......................6 4. Security and Telecommunications Testing Summary ....................8 5. Volume Testing Summary ..............................................................9 6. Accessibility ....................................................................................9 IV. Compliance with State Laws and Regulations ...............................................13 V. Conclusion .......................................................................................................15 SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 1 | P age I. INTRODUCTION 1. Scope This report presents the test results for all phases of the certification test of the KNOWINK PollPad Version 2.5.2.01b. The purpose of the testing is to test the compliance of the electronic poll book with California laws. Testing also uncovers other findings, which do not constitute non-compliance, and those findings are reported to the electronic poll book vendor to address the issues procedurally. The procedures for mitigating any additional findings are made to the documentation, specifically the KNOWINK PollPad 2.5.2.01b User Guide. 2. Summary of the Application KNOWiNK submitted an application for the PollPad 2.5.2.01b system on June 26, 2020. The system is comprised of the following major components: • Apple iPad, Generation 5, 32 Gigabyte • Apple iPad, Generation 6, 32 Gigabyte • Apple iPad, Generation 6, 32 Gigabyte (Cellular) • Apple iPad, Generation 6, 128 Gigabyte • Apple iPad, Generation 7, 32 Gigabyte • Apple iPad, Generation 7, 32 Gigabyte (Cellular) • Apple iPad Air 2, 16 Gigabyte • iOS, Version 13.6 • iOS, Version 13.6.1 • iOS, Version 13.7 • PollPad Application, Version 2.5.2.01b • Star Micronics Printer, Model TSP650II • Star Micronics Printer, Model TSP700II • Brother Pocket Printer, Model JET PJ-763MFi • ePulse, Version 2.5.2.01b In addition to these major components, which includes the executable code and the source code, KNOWiNK was required to submit the following: (1) the technical documentation package (TDP); (2) all the hardware components to field two complete working versions of the system, including all peripheral devices, one for the Functional Test Phase and one for the Security and Telecommunications Penetration Test Phase; (3) all the peripherals that would be in the polling place; and (4) the KNOWiNK PollPad 2.5.2.01b User Guide. 3. Contracting and Consulting The Secretary of State released a Request for Quote (RFQ) for assistance with the software, security and telecommunications and accessibility testing. The statement of work (SOW) also had an option for the Secretary of State to use the awarded contractor for additional software, security and telecommunications and accessibility testing, if it deemed necessary. SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 2 | P age Through the formal California contracting process, the Secretary of State awarded a contract to SLI Compliance. II. SUMMARY OF THE SYSTEM The system consists of fifteen (15) components: 1. Apple iPad, Generation 5, 32 Gigabyte The iPad 5 comes with 32GB of storage capacity and is Wi‑Fi, and Bluetooth 4.2 technology compliant. 2. Apple iPad, Generation 6, 32 Gigabyte The iPad 6 comes with 32GB of storage capacity and is Wi‑Fi, and Bluetooth 4.2 technology compliant. 3. Apple iPad, Generation 6, 32 Gigabyte (Cellular) The iPad 6 comes with 32GB of storage capacity and is cellular, Wi‑Fi, and Bluetooth 4.2 technology compliant. 4. Apple iPad, Generation 6, 128 Gigabyte The iPad 6 comes with 162GB of storage capacity and is Wi‑Fi, and Bluetooth 4.2 technology compliant. 5. Apple iPad, Generation 7, 32 Gigabyte The iPad 7 comes with 32GB of storage capacity and is Wi‑Fi, and Bluetooth 4.2 technology compliant. 6. Apple iPad, Generation 7, 32 Gigabyte (Cellular) The iPad 7 comes with 32GB of storage capacity and is cellular, Wi‑Fi, and Bluetooth 4.2 technology compliant. 7. Apple iPad Air 2, 16 Gigabyte The iPad Air 2 comes with 16GB of storage capacity and is Wi‑Fi, and Bluetooth 4.2 technology compliant. 8. iOS, Version 13.6 iOS is an Apple, Inc. mobile operating system exclusively for its hardware. It is the operating system that presently powers many of the company's mobile devices. 9. iOS, Version 13.6.1 iOS is an Apple, Inc. mobile operating system exclusively for its hardware. It is the operating system that presently powers many of the company's mobile devices. 10. iOS, Version 13.7 iOS is an Apple, Inc. mobile operating system exclusively for its hardware. It is the operating system that presently powers many of the company's mobile devices. SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 3 | P age 11. PollPad Application, Version 2.5.2.01b The PollPad solution provides an electronic voter check-in and verification process for election officials. PollPad is an Apple iPad application requiring no appendages for operation. The application also provides built-in election management tools, reporting tools and customizable workflows. 12. Star Micronics Printer, Model TSP650II Star Micronics' TSP650II receipt printer is offered with a variety of interface options and is an iOS compatible Bluetooth printer. 13. Star Micronics Printer, Model TSP700II Star Micronics' TS700II receipt printer is offered with a variety of interface options and is an iOS compatible Bluetooth printer. 14. Brother Pocket Printer, Model JET PJ-763MFi Brother JET PJ-763MFi printer is offered with a variety of interface options and is an iOS compatible Bluetooth printer. 15. ePulse, Version 2.5.2.01b ePulse is a web-based monitoring platform that connects polling places to the centralized location and facilitates communication between administrators and poll workers. It connects poll books, provides polling place status, enables trouble resolution, provides secure voter data management, and allows for poll worker supervision. III. TESTING INFORMATION AND RESULTS 1. Background KNOWiNK submitted an application to the Secretary of State for certification of the KNOWiNK PollPad Version 2.5.2.01b (PollPad) on June 26, 2020. Examination of this system was conducted by the State’s technical consultant SLI Compliance with oversight by Secretary of State Staff. Functional Testing, Volume Testing, Source Code Review, Security and Telecommunications Testing, and an Accessibility Review were performed by SLI Compliance from August 3 to September 23, 2020. 2. Functional Testing Summary SLI Compliance performed functional examination of the PollPad system. During the examination, all electronic poll book functions outlined in the KNOWiNK PollPad 2.5.2.01b User Guide documentation were exercised. Functional Testing KNOWiNK provided seven (7) electronic poll books (iPad’s with iOS version 13.6, iOS version 13.6.1, iOS version 13.7, and the KNOWiNK PollPad 2.5.2.01b application), access to the KNOWiNK Precinct Central Console website (ePulse), and three printers (Star Micronics TSP650II, Star Micronics TSP700II, and Brother JET PJ-763MFi) for functional testing. SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 4 | P age SLI Compliance configured the electronic poll books and exercised their functionality according to the vendor provided technical documentation. The exercises included verification of expected functions of the system as outlined in the vendor provided technical documentation, execution of test cases and verification of the electronic poll book’s compliance with State statutes and regulations. Issues & Observations: During Functional Testing, approximately twenty-two (22) issues were identified. All twenty-two (22) issues required mitigation. a. Documentation Nineteen (19) issues were related to minor documentation discrepancies and were provided to KNOWiNK for modification. The documentation was subsequently modified and the changes verified by SLI Compliance and Secretary of State Staff. b. Hardware There were no issues related to the hardware. c. Software Six (6) issues were related to the software and were provided to KNOWiNK [S1] for mitigation. The mitigations were implemented and verified by SLI Compliance and Secretary of State Staff. The discrepancy and vendor mitigation/response are listed in the following table: Table 2A: Functional Testing Software Issues Discrepancy Vendor Mitigation/Response Although the status indicator implies an incomplete 'Import Voter File' status indicators import, the import successfully completes, and this does imply incomplete import after not hinder performance. KNOWiNK is committed to import completes. resolving this issue in the next version of the system. KNOWiNK has added use procedure instructions ‘Emailing Location Button’ advising jurisdictions how to disable the ‘Emailing function for wrong location voters Location Button.’ KNOWiNK is committed to not working. resolving this issue in the next version of the system. 'Registration Time' display column KNOWiNK has added use procedure instructions within ‘Summary Report’ function advising jurisdictions how to disable the ‘Registration not displaying registration times for Time’ display column. KNOWiNK is committed to all voters. resolving this issue in the next version of the system. This was mitigated by requiring KNOWiNK and/or Poll Pad application capable of jurisdictions to exclude the California driver’s license storing a voter’s California driver’s number and Social Security Number during the voter license number, and Social Security file import from the jurisdiction’s election management Number via import of the voter file system, and disable any functionality that captures from the jurisdiction’s election driver’s license numbers, and Social Security Number’s management system. or portions thereof. SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 5 | P age All iPad Operating System (iOS) This was mitigated by requiring KNOWiNK and/or settings (e.g., updates, date and jurisdictions to deploy devices in Guided Access mode. time, WiFi, etc.) are accessible and Guided Access restricts the iOS device to the Poll Pad capable of manipulation. application. The Poll Pad application does not This was mitigated by adjusting the iPad settings to require a user specific username require a password anytime the iPad is accessed. and password be entered when However, user specific usernames and passwords are accessing the application. not available for the Poll Pad application. 3. Software (Source Code) Review Testing Summary SLI Compliance performed a review of the PollPad source code. During testing, SLI conducted a security and integrity review of the PollPad source code. Zero (0) issues were identified within the PollPad source code. 4. Security and Telecommunications Testing SLI Compliance performed Security and Telecommunications testing on the PollPad. During testing, a full review of the PollPad was performed to analyze for findings against applicable requirements. The discrepancy and vendor mitigation/response are listed in the following table: Table 4A: Security and Telecommunications Testing Note: The following discrepancy pertains to KNOWiNK’s ePulse web-based monitoring platform and is considered by SLI of minimal impact to overall system security. Discrepancy Vendor Mitigation/Response Two Password Fields with KNOWiNK is committed to resolving this issue in the next Autocomplete Enabled version of the system. 5. Volume Testing Summary For approximately two days, 250 mock voters were processed on the KNOWiNK Poll PadPollPad v. 2.5.2.01b electronic poll book system. Zero (0) unexpected results or issues were encountered during the Volume Test. 6. Accessibility SLI evaluated the PollPad against the applicable portions of the Web Content Accessibility Guidelines (WCAG) 2.0 and Section 508 of the Rehabilitation Act of 1973 for compliance. Zero (0) unexpected results or issues were encountered during the Accessibility Review. IV. COMPLIANCE WITH STATE LAWS AND REGULATIONS Two (2) sections of the California Code of Regulations, sections 20150 and 20158, describe in detail the requirements any electronic poll book system must meet in order to be approved for use in California elections. These sections are described in detail and analyzed for compliance below. 1) §20150(a)(1): An electronic poll book shall contain, at a minimum, all of the following voter registration data: Name, Address, District/Precinct, Party preference, SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 6 | P age Voter status, Whether or not the voter has been issued a vote by mail ballot, Whether or not the vote by mail ballot has been recorded as accepted by the elections official, and Whether or not the voter’s identification must be verified. The system meets this requirement. 2) §20150(a)(2): An electronic poll book shall not contain the following voter registration data: California driver’s license number, and Social Security Number or portion thereof. The system meets this requirement. 3) §20158(a): The electronic poll book shall not be connected to a voting system at any time. The system meets this requirement. 4) §20158(b): The electronic poll book shall demonstrate that it accurately processes all activity as prescribed in the vendor’s application packet. The system meets this requirement. 5) §20158(c): The electronic poll book shall be capable of operating for a period of at least two hours on backup power, such that no data is lost or corrupted nor normal operations interrupted. When backup power is exhausted, the electronic poll book shall retain the contents of all memories intact. The system meets this requirement. 6) §20158(d): The electronic poll book shall be compatible with: all voter registration election management systems used in the State of California, including any software system (middle ware) used to prepare the list of voters for the equipment, and any hardware attached to the electronic poll book (e.g. bar code scanners, signature capture devices, transport media, printers, etc.). The system meets this requirement. 7) §20158(e): An electronic poll book shall contain all of the following voter registration data: Name, Address, District/Precinct, Party preference, Voter status, Whether or not the voter has been issued a vote by mail ballot, Whether or not the vote by mail ballot has been recorded as accepted by the elections official, and Whether or not the voter’s identification must be verified. The system meets this requirement. 8) §20158(f): The electronic poll book shall encrypt all voter registration data at rest and in transit, utilizing a minimum of Advanced Encryption Standard (AES) 256-bit data encryption, based on recognized industry standards. The system meets this requirement. 9) §20158(g): The electronic poll book shall provide reliable transmission of voter registration and election information. The system meets this requirement. 10) §20158(h): The electronic poll book shall have the capability to store a local version of the electronic list of registered voters to serve as a backup. SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 7 | P age The system meets this requirement. 11) §20158(i): The electronic poll book shall produce a list of audit records that reflect all actions of the system, including in-process audit records that display all transactions. Such audit records shall be able to be exported in non-proprietary, human readable format. The system meets this requirement. 12) §20158(j): The electronic poll book shall enable a poll worker to easily verify that the electronic poll book: has been set up correctly, is working correctly so as to verify the eligibility of the voter, is correctly recording that a voter has voted, and has been shut down correctly. The system meets this requirement. 13) §20158(k): After the voter has been provided with a ballot, the electronic poll book shall permit a poll worker to enter information indicating that the voter has voted at the election. The electronic poll book shall have the capability to transmit this information to every other electronic poll book in the county utilizing the same list of registered voters. The system meets this requirement. 14) §20158(l): The electronic poll book shall permit voter activity to be accurately uploaded into the county’s voter registration election management system. The system meets this requirement. 15) §20158(m): During an interruption in network connectivity of an electronic poll book, all voter activity shall be captured and the electronic poll book shall have the capacity to transmit that voter activity upon connectivity being restored. The system meets this requirement. 16) §20158(n): If the electronic poll book uses an electronic signature capture device, the device shall: produce a clear image of the electronic signature capable of verification, and retain and identify the signature of the voter The system meets this requirement. 17) §20158(o): The electronic poll book shall have the capacity to transmit all information generated by the voter or poll worker as part of the process of receiving a ballot, including the time and date stamp indicating when the voter voted, and the electronic signature of the voter, where applicable, to the county’s voter registration election management system. The system meets this requirement. 18) §20158 (p): The Secretary of State recommends electronic poll books not be enabled or installed with any technologies delineated in the Institute of Electrical and Electronics Engineers’ (IEEE) 802.11 wireless local area network (LAN) standards. However, should an electronic poll book be enabled or installed with a wireless technology, the following shall be utilized: a minimum of 256-bit data encryption, a minimum of Wireless Protected Access (WPA) 2 security enabled, compliance with Payment Card Industry Data Security Standards (PCI DSS) version 3.2, a dedicated SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 8 | P age wireless access point (WAP) or connection utilized only by county employees or elections officials and void of public or guest access, and devices equipped with one or more of the following: biometric authentication, multi-factor authentication, compliance with current PCI DSS version 3.2 password requirements, or remote wipe technology set to automatically clear a device upon 8 eight failed login attempts. The system meets this requirement. 19) §20158 (q): Jurisdictions utilizing a wide area network (WAN) to transmit voter registration data from an electronic poll book to a centralized location shall utilize one of the following: a dedicated leased line, a hardware virtual private network (VPN), or a dedicated cellular connection void of public or guest access. The system meets this requirement. 20) §20158 (r): The electronic poll book shall be reviewed for accessibility. The system meets this requirement. V. CONCLUSION The KNOWiNK PollPad Electronic Poll Book System, Version 2.5.2.01b, in the configuration tested and documented by SLI Compliance and the California Secretary of State, is compliant with all California laws. SECRETARY OF STATE’S STAFF REPORT – KNOWINK PollPad Version 2.5.2.01b 9 | P age